Background

• As detailed in our recent client alert, California’s Fair Investment Practices by Venture Capital Companies Law (FIPVCC) requires certain venture capital companies with a California nexus to collect and annually report demographic information of portfolio company founders. Initial compliance under the law required filing of initial demographic reports by April 1, 2026.
• The California Department of Financial Protection and Innovation (DFPI) recently announced that implementation and enforcement of the FIPVCC will be suspended pending completion of formal rulemaking and until final regulations are in place. Covered entities are no longer required to submit registrations or file reports by the previously announced April 1, 2026, deadline.

Rulemaking Process and Timeline

On March 17, 2026, DFPI announced it will initiate formal rulemaking under the FIPVCC in response to comments received from venture capital companies, industry associations, and other stakeholders affected by the law. As part of this announcement, DFPI has suspended implementation and enforcement of the FIPVCC pending completion of the rulemaking process and the adoption of final regulations.

DFPI will begin formal rulemaking later this year, with the stated goal of promoting clarity, collaboration, and transparency in the administration of the FIPVCC. Prior to commencing formal rulemaking, DFPI will engage in stakeholder outreach and solicit input from venture capital companies, industry associations, founders, investors, and other affected parties. DFPI will notify its subscribers and covered entities that registered under the FIPVCC when formal rulemaking begins. Once initiated, formal rulemaking must be completed within one year under California administrative law requirements.

Key Takeaways for Affected Venture Capital Companies

• April 1 Deadline Suspended. Covered entities are no longer required to register or to file FIPVCC reports by April 1, 2026. No further action is required by covered entities at this time.
• Consider Participating in the Rulemaking Process. The pre-rulemaking comment period represents a meaningful opportunity for venture capital companies and other stakeholders to shape the final regulations.
• Stay Informed of Updates. DFPI will provide further notice regarding specific timelines and opportunities to submit comments. Affected parties should continue to monitor DFPI communications and subscribe to updates to ensure timely awareness of developments. To subscribe to updates directly from DFPI, visit the department’s subscription page and select “Venture Capital Companies” on the next page.

If you have questions about FIPVCC, the rulemaking process, or how these developments may affect your venture capital fund or investment activities, please contact your Wilson Sonsini attorney or any member of the firm’s Emerging Companies and Venture Capital practice.